Chicataw Construction, Inc.

A firm protested a General Services Administration (GSA) contract award for a chilling/cooling tower replacement, contending that GSA's evaluation of past performance was unreasonable. GAO held that (1) GSA made reasonable efforts to contact the required minimum of three past performance references, and ultimately used a neutral rating for the reference it was unable to reach, and (2) there is nothing in the record to support a conclusion that the resulting increase in the protester's past performance score would materially alter GSA's selection decision. Accordingly the protest was denied.